BACT Determination Information

Transcription

1 ACTIVE SMAQMD BACT CLEARINGHOUSE CATEGORY: PRINTING PROCESS BACT Size: Minor Source BACT PRINTING PRESS BACT Determination Number: 138 BACT Determination Date: 1/13/2017 Equipment Information Permit Number: N/A -- Generic BACT Determination Equipment Description: PRINTING PRESS Unit Size/Rating/Capacity: Non-Heatset Lithographic Offset Equipment Location: ROCs NOx SOx PM10 PM2.5 CO LEAD Standard: Technology Description: Basis: Standard: Technology Description: Basis: Standard: Technology Description: Basis: Standard: Technology Description: Basis: Standard: Technology Description: Basis: Standard: Technology Description: Basis: Standard: Technology Description: Basis: BACT Determination Information See Comments Section Below VOC control device that has an overall system efficiency (collection and destruction) of at least 98.5% for VOC and/or Materials in compliance with SMAQMD Rule 450 (see Comments below). Achieved in Practice N/A N/A N/A N/A N/A N/A Comments: Sources emitting < 4,697 lbs uncontrolled VOC per year -- Use of materials compliant with SMAQMD Rule Graphic Arts. Sources emitting 4,697 lbs uncontrolled VOC per year -- Use of materials compliant with SMAQMD Rule Graphic Arts and a VOC control device that has an overall system efficiency (collection and destruction) of at least 98.5% for VOC. District Contact: Joe Carle Phone No.: (916) jcarle@airquality.org

2 B th Street, Third Floor Sacramento, CA BEST AVAILABLE CONTROL TECHNOLOGY DETERMINATION DETERMINATION NO.: 138 DATE: December 14, 2016 ENGINEER: Joe Carle Category/General Equip Description: Equipment Specific Description: Equipment Size/Rating: Printing Process Printing Press Non-Heatset Lithographic Offset Minor Source BACT Previous BACT Det. No.: 76 This BACT determination will update Determination #76 for lithographic offset printing presses that are non-heatset. BACT ANALYSIS A: ACHIEVED IN PRACTICE (Rule 202, 205.1a) The following control technologies are currently employed as BACT for lithographic offset printing presses that are non-heatset by the following air pollution control districts: District/Agency Best Available Control Technology (BACT)/Requirements BACT Source: EPA RACT/BACT/LAER Clearinghouse US EPA VOC NOx SOx PM10 PM2.5 CO N/A No BACT determinations found for non-heatset lithographic offset printing N/A No BACT determinations found for non-heatset lithographic offset printing N/A No BACT determinations found for non-heatset lithographic offset printing N/A No BACT determinations found for non-heatset lithographic offset printing N/A No BACT determinations found for non-heatset lithographic offset printing N/A No BACT determinations found for non-heatset lithographic offset printing T-BACT There are no T-BACT standards published in the clearinghouse for this category RULE REQUIREMENTS: None

3 BACT Determination Printing Press Non-Heatset Lithographic Offset December 14, 2016 Page 2 of 12 District/Agency Best Available Control Technology (BACT)/Requirements BACT Source: ARB BACT Clearinghouse Note: All BACT determinations published in the ARB BACT Clearinghouse are at least 10 years old. ARB ARB BACT Clearinghouse* VOC VOC of fountain solution not to exceed 0.17 lb/gal and Ink VOC 300 g/l. NOx No standard SOx No standard PM10 No standard PM2.5 No standard CO No standard * This BACT determination was found to be the most stringent Achieved in Practice BACT determination published in the ARB clearinghouse based on the control description. The VOC limits seem to be specific to the unit which the BACT determination was created considering higher limits were allowed at later dates than others. T-BACT There are no T-BACT standards published in the clearinghouse for this category. RULE REQUIREMENTS: None BACT Lithographic printing press; all sizes VOC Low VOC inks, coatings, fountain solutions compliant with Rule 450 NOx No standard SOx No standard PM10 No standard PM2.5 No standard CO No standard SMAQMD T-BACT There are no T-BACT standards published in the clearinghouse for this category. RULE REQUIREMENTS: Rule 450 Graphic Arts Operations (10/23/2008) MATERIAL TYPE VOC CONTENT g/l (lb/gal) Less water and exempt compounds Printing Ink 300 (2.5) Adhesive 150 (1.25) Coating 300 (2.5)

4 BACT Determination Printing Press Non-Heatset Lithographic Offset December 14, 2016 Page 3 of 12 District/Agency Best Available Control Technology (BACT)/Requirements VOC Content for Fountain Solution Materials: MATERIAL TYPE Coldset Web Offset Lithography Fountain Solutions Containing Alcohol 1. Chilled Using Refrigerated Chiller 2. Non-Chilled Fountain Solutions Containing No Alcohol 1. Chilled Using Refrigerated Chiller 2. Non-Chilled VOC Content Limits Including Water And Exempt Compounds % By Weight Shall not be used Shall not be used 5 5 Sheet-fed Offset Lithography with maximum sheet size greater than 11 X 17 inches or total solution reservoir greater than 1 gallon Fountain Solutions Containing Alcohol 1. Chilled Using Refrigerated Chiller 2. Non-Chilled Fountain Solutions Containing No Alcohol 1. Chilled Using Refrigerated Chiller 2. Non-Chilled All Other Presses (includes offset lithographic presses exempt pursuant to Rule 450, Section 110.9) 1. Chilled Using Refrigerated Chiller 2. Non-Chilled 10 8 VOC Content for Solvent Cleaning Materials: MATERIAL TYPE General (e.g., maintenance, repair, solvent, wipe) Cleaning VOC Content g/l (lb/gal) Including Water and Exempt Compounds 25 (0.21) Application Equipment Cleaning General (not specifically listed below) 25 (0.21) Lithographic and Letter Press Printing On-Press Components Removable Press Components 100 (0.83) 25 (0.21) Ultraviolet/Electron Beam Inks 100 (0.83) Control Devices for Lithographic Offset Non-Heatset Printing Presses must have an overall system efficiency of 67%

5 BACT Determination Printing Press Non-Heatset Lithographic Offset December 14, 2016 Page 4 of 12 District/Agency Best Available Control Technology (BACT)/Requirements BACT Source: SCAQMD BACT Guidelines for Non-Major Polluting Facilities, page 98. Lithograph or Offset, Non-heatset VOC Low VOC fountain solution ( 8% by volume VOC); Low vapor pressure ( 10 mm Hg VOC composite partial pressure) or low VOC ( 100 g/l) blanket and roller washes; oil-based or UV-curable inks; and compliance with AQMD rules 1130 and 1171 ( ) NOx No standard SOx No standard PM10 No standard PM2.5 No standard CO No standard T-BACT There are no T-BACT standards published in the clearinghouse for this category. RULE REQUIREMENTS: Reg XI, Rule 1130 Graphic Arts (5/2/2014) South Coast AQMD Graphic Art Material VOC CONTENT g/l Less water and exempt compounds Adhesive 150 Coating 300 Offset Lithographic Ink 300 VOC Content Limits Fountain Solution Grams of VOC Per Liter of Material Sheet-Fed Using Alcohol without Refrigerated Chiller 50 Using Alcohol with Refrigerated Chiller 85 Using Alcohol Substitute 50 Non-Heatset Web-Fed Using Alcohol Substitute without Refrigerated Chiller 50 Using Alcohol Substitute with Refrigerated Chiller An emission control device must have a control efficiency of at least 95% and the emission collection system must have a collection efficiency of at least 90%. Reg XI, Rule 1171 Solvent Cleaning Operations (5/1/2009)

6 BACT Determination Printing Press Non-Heatset Lithographic Offset December 14, 2016 Page 5 of 12 District/Agency Best Available Control Technology (BACT)/Requirements Solvent Cleaning Activity VOC g/l (lb/gal) Cleaning of Coatings or Adhesives Application Equipment 25 (0.21) Cleaning of Ink Application Equipment General 25 (0.21) Lithographic (Offset) of Letter Press Printing Roller Wash, Blanket Wash, & On-Press Components 100 (0.83) Removable Press Components 25 (0.21) Ultraviolet Ink/ Electron Beam Ink Application Equipment 100 (0.83) BACT Source: NSR Requirements for BACT, page Graphic Arts Operations (< 5 tons/year) VOC 1. Use of low VOC fountain solution (< 6% VOC by volume), 2. Capture & recycle blanket and roller tray wash, 3. Use of cleanup solvent which has either less than 200 g VOC/l or vapor pressure of less than 5 mm HG at 20 O C, 4. Use of metering roll cleanup solvent which has either less than 100 g VOC/l or vapor pressure less than 10 mm HG at 20 O C, and 5. Use of inks which have a VOC content of less than 300 g/l (2.5 lb/gal) NOx No standard SOx No standard PM10 No standard PM2.5 No standard CO No standard San Diego County APCD T-BACT There are no T-BACT standards published in the clearinghouse for this category. RULE REQUIREMENTS: Regulation 4, Rule Graphic Arts Operations (11/9/2011) - Graphic arts materials, except adhesives, must contain < 300 g VOC/l (2.5 lb/gal) - Adhesives containing not more than 150 grams of VOC per liter (1.25 lb/gal), as applied, less water and less exempt compounds - Fountain solutions must contain no more than 5% VOC by volume - Fountain solutions refrigerated to a temperature below 60 O F must contain no more than 8.5% VOC by volume - Cleaning material must have a VOC content less than 100 g/l or the total VOC vapor pressure of the cleaning material is 5mm of Hg at 20 O C or less.

7 BACT Determination Printing Press Non-Heatset Lithographic Offset December 14, 2016 Page 6 of 12 District/Agency Best Available Control Technology (BACT)/Requirements - Control devices must have a capture and control efficiency of 85% by mass. BACT Source: BAAQMD BACT Guidelines, Document # , Rev. 4, 8/24/98 Lithographic or Offset Printing Non-Heatset VOC Achieved in Practice: Low VOC fountain solution ( 8% by vol.); and minimum possible VOC blanket was and roller and tray washes; and cleanup solvents w/ 7.5 lb VOC/gal and VOC vapor pressure 25 mm Hg or 30% by volume VOC; and kerosene-like oil based inks. Technologically Feasible/Cost Effective: Low VOC fountain solution ( 6% by vol.); and automatic blanket and roller was with solvent capture and recycle; and cleanup solvents with 2.5 lb VOC/gal or VOC vapor pressure 5 mm Hg; and kerosene-like oil based inks. If cost-effective, capture and vent VOC to afterburner or carbon adsorption system with 98.5 destruction/recovery device efficiency; or VOC outlet 10 ppmv. NOx No standard SOx No standard PM10 No standard PM2.5 No standard CO No standard RULE REQUIREMENTS: Bay Area AQMD Reg 8, Rule 20 Graphic Arts Printing and Coating Operations (11/19/2008) Product Limit grams VOC per liter of product as Product applied, less water and exempt solvent (lbs/gal) Less than: Ink 300 (2.5) Coating 300 (2.5) Adhesive 150 (1.25) Web Splicing Adhesive 300 (2.5) Fountain Solution must be 8% VOC by volume Cleaning Product Limits: Equipment VOC g/l (lb/gal) including water For Press Equipment, except Other Press Parts Specialty Lithographic Press 100 (0.83) Lithographic Press, by either Manual or Automatic Washing 100 (0.83) Adhesive Application Equipment 25 (0.21) Ultraviolet Ink Removal, Any Press Type 100 (0.83) Other Press Parts 25 (0.21) Emission control systems must have an overall efficiency of 75% on a mass basis.

8 BACT Determination Printing Press Non-Heatset Lithographic Offset December 14, 2016 Page 7 of 12 District/Agency Best Available Control Technology (BACT)/Requirements BACT Source: SJVUAPCD BACT Guideline Lithographic or Offset Printing Non-Heatset VOC Using materials with the following VOC contents: Inks: less than 5% VOC by weight (less water and exempt compounds) or less than 30% VOC by weight (less water and exempt compounds) for high end graphics Fountain Solutions: less than 5% by volume for coldest web offset lithographic, less than 5% by volume for sheet-fed offset lithographic with maximum sheet size greater than 11x17 inches, and less than 8% by volume for high end graphics NOx No standard SOx No standard PM10 No standard PM2.5 No standard CO No standard RULE REQUIREMENTS: Rule 4607 Graphic Arts and Paper, Film, Foil and Fabric Coatings (12/18/2008) San Joaquin Valley APCD VOC content limits for inks, coatings, and adhesives Material Grams of VOC per liter (lb/gal), less water and exempt compounds, as applied Inks 300 (2.5) Coatings 300 (2.5) Adhesives 150 (1.25) VOC content limits for fountain solution Fountain Solution Percent VOC by Volume Coldset Web Offset Lithographic 5.0 Sheet-fed Offset Lithographic with Maximum Sheet Size greater than 11 X 17 Inches 5.0 All Other Presses 8.0 VOC content limits for solvent cleaning Type of Solvent Cleaning Operation Product Cleaning During Manufacturing Process; or Surface Preparation for Coating, Ink, on Adhesive Application Limit Grams of VOC/Liter of Material (lb/gal) 25 (0.21)

9 BACT Determination Printing Press Non-Heatset Lithographic Offset December 14, 2016 Page 8 of 12 District/Agency Best Available Control Technology (BACT)/Requirements Repair and Maintenance Cleaning 25 (0.21) Cleaning of Coating or Adhesive Application Equipment Cleaning of Ink Application Equipment 25 (0.21) General 25 (0.21) Lithographic (Offset) or Letterpress Printing Roller Wash Step (0.83) Roller Wash Step 2; Roller Wash not specified; Blanket Wash, and On-Press Components 100 (0.83) Removable Press Components 25 (0.21) Ultraviolet Ink/Electron Beam Ink Application Equipment (except screen printing) 100 (0.83) Lithographic offset non-heatset printing presses venting to a control device must have an overall capture and control efficiency of 75% on a mass basis. VOC NOx SOx PM10 PM2.5 CO SUMMARY OF ACHIEVED IN PRACTICE CONTROL TECHNOLOGIES 1. Use of materials compliant with SCAQMD Rule 1130 and 1171, SMAQMD Rule 450, or SJVUAPCD Rule [SCAQMD, SMAQMD, SJVUAPCD] 2. Use of materials compliant with SDCAPCD Rule [SDCAPCD] 3. Use of materials compliant with BAAQMD Regulation 8 Rule 20. [BAAQMD] 1. No standard [SMAQMD, SCAQMD, SDCAPCD, BAAQMD, SJVUAPCD] 1. No standard [SMAQMD, SCAQMD, SDCAPCD, BAAQMD, SJVUAPCD] 1. No standard [SMAQMD, SCAQMD, SDCAPCD, BAAQMD, SJVUAPCD] 1. No standard [SMAQMD, SCAQMD, SDCAPCD, BAAQMD, SJVUAPCD] 1. No standard [SMAQMD, SCAQMD, SDCAPCD, BAAQMD, SJVUAPCD] Emission limits for inks, coatings, and solvent cleaning are consistent across SCAQMD Rule 1130 and 1171, SMAQMD Rule 450, and SJVUAPCD Rule Emission limits for fountain solutions vary from rule to rule mostly based on how the emission limit is expressed. SCAQMD lists emission limits for fountain solutions in grams per liter while SMAQMD expresses the limit in percent VOC by mass, and SJVUAPCD expresses the limits in percent VOC by volume. It is difficult to compare these limits because percent by mass and volume can vary from solution to solution depending upon its physical properties. The EPA Control Techniques Guidelines for Offset Lithographic Printing and Letter Press Printing (CTG) lists recommends emission standards as percent mass. The SMAQMD Rule also lists these identical standards as a percent mass. SCAQMD updated their emission limits for fountain solutions in In their staff report for these amendments they state that their emission limits are equivalent to those of the CTG except they have converted the limits to grams per liter to remain consistent with the previous emission limits for fountain solutions. Additionally, in 2008 amendments were made to SJVUAPCD Rule 4607, according to the associated staff report, to align the emission standards to that of other districts and the CTG.

10 BACT Determination Printing Press Non-Heatset Lithographic Offset December 14, 2016 Page 9 of 12 Even though the emission limits for fountain solutions differ in the way they are expressed between the SCAQMD, SMAQMD, and SJVUAPCD all districts claim to be equivalent to the recommendations in the CTG. In order to remain consistent with the CTG and SMAQMD Rule 450 for fountain solutions will be expressed on a percent mass basis. The following control technologies have been identified as the most stringent, achieved in practice control technologies: BEST CONTROL TECHNOLOGIES ACHIEVED Pollutant Standard Source VOC Use of materials compliant with SMAQMD Rule 450 Graphic Arts. SMAQMD (Rule 450) NOx SOx PM10 PM2.5 CO No standard No standard No standard No standard No standard SMAQMD, SCAQMD, SJVUAPCD, SDCAPCD, BAAQMD SMAQMD, SCAQMD, SJVUAPCD, SDCAPCD, BAAQMD SMAQMD, SCAQMD, SJVUAPCD, SDCAPCD, BAAQMD SMAQMD, SCAQMD, SJVUAPCD, SDCAPCD, BAAQMD SMAQMD, SCAQMD, SJVUAPCD, SDCAPCD, BAAQMD B. TECHNOLOGICALLY FEASIBLE AND COST EFFECTIVE (Rule 202, b.): Technologically Feasible Alternatives: Any alternative basic equipment, fuel, process, emission control device or technique, singly or in combination, determined to be technologically feasible by the Air Pollution Control Officer. The table below shows the technologically feasible alternatives identified as capable of reducing emissions beyond the levels determined to be Achieved in Practice as per Rule 202, a. VOC NOx SOx PM10 PM2.5 CO 1. VOC control device with 98.5% Overall System Efficiency N/A N/A N/A N/A N/A Cost Effective Determination: After identifying the technologically feasible control options, a cost analysis is performed to take into consideration economic impacts for all technologically feasible controls identified.

11 BACT Determination Printing Press Non-Heatset Lithographic Offset December 14, 2016 Page 10 of 12 Maximum Cost per Ton of Air Pollutants Controlled 1. A control technology is considered to be cost-effective if the cost of controlling one ton of that air pollutant is less than the limits specified below (except coating operations): Pollutant Maximum Cost ($/ton) ROG 17,500 NO X 24,500 PM 10 11,400 SO X 18,300 CO TBD if BACT triggered Cost Effectiveness Analysis Summary Background: Current District BACT analysis for lithographic printing operations assumed pressroom emissions similar to that of VOC emissions in spray coating operations. Top down BACT analyses performed by the District recently for control technologies using VOC incineration and carbon adsorption in coating operations resulted in a cost effectiveness level of 4,663 lb or less per year. This was reported in the District s BACT Determinations No. 118 & 119. The objective of this BACT determination is to verify the assumption that VOC emissions in graphic arts printing operation is similar to spray coating operation. Lithographic printing operation will be reviewed by using the pressroom as the emission source and updating the cost inputs in accordance with the EPA OAQPS Air Pollution Control Cost Manual (Third Edition). Basic assumptions: 1) Single 4-color lithographic printing press operation. 2) Press room dimensions: 40 W x 60 L x 20 H (because the press room is relatively small a hood is not necessary) 3) The press room is assumed to be the enclosure with an overall system efficiency of 98.5% and venting to the control device through a general ventilation system. 4) General ventilation with an 8,000 CFM blower (10 air changes per hour). 5) Cost calculations and assumptions are based on the EPA Air Pollution Control Cost Manual. Carbon Adsorption System Equipment Life = 10 years Total Capital Investment = $114,290 Annualized Total Capital Investment = $17,417 per year Direct Annual Cost = $15,696 per year Indirect Annual Cost = $7,377per year Total Annual Cost = $$40,491 per year VOC Removed = 2.31 tons per year

12 BACT Determination Printing Press Non-Heatset Lithographic Offset December 14, 2016 Page 11 of 12 Cost of VOC Removal = $17, per ton reduced A detailed calculation of the cost effectiveness for VOC removal with a carbon absorber is shown in Appendix B. Uncontrolled VOC emissions of 4,697 lb/year or greater is the cost-effective threshold for control equipment using carbon absorption control technology Thermal Oxidizer: Equipment Life = 10 years Total Capital Investment = $401,329 Annualized Total Capital Investment = $76,839 per year Direct Annual Cost = $173,047 per year Indirect Annual Cost = $24,228 per year Total Annual Cost = $274,114per year VOC Removed = tons per year Cost of VOC Removal = $17, per ton reduced A detailed calculation of the cost effectiveness for VOC removal with a thermal oxidizer is shown in Appendix C. Uncontrolled VOC emissions of 31,797 lb/year or greater is the cost-effective threshold for control equipment using thermal oxidation control technology. Conclusion: In this analysis, different emission operating levels are presented with the corresponding total cost per ton of VOC controlled using either a carbon adsorption control or a thermal oxidizer. Uncontrolled VOC emission level of 4,697 lb per year or greater must be reached in order for the carbon absorption control option to be cost effective. Uncontrolled VOC emission level of 31,797 lb per year or greater must be reached in order for a thermal oxidizer to be cost effective. The emissions levels for the cost effectiveness of controls is based on the District cost effective limit for ROC of $17,500 per ton controlled. C. SELECTION OF BACT: BACT FOR LITHOGRAPHIC OFFSET PRINTING PRESSES THAT ARE NON-HEATSET EMITTING < 4,697 LBS UNCONTROLLED VOC PER YEAR Pollutant Standard Source VOC Use of materials compliant with SMAQMD Rule 450 Graphic Arts. SMAQMD (Rule 450) NOx No standard SMAQMD, SCAQMD, SJVUAPCD, SDCAPCD, BAAQMD SOx No standard SMAQMD, SCAQMD, SJVUAPCD, SDCAPCD, BAAQMD PM10 No standard SMAQMD, SCAQMD, SJVUAPCD, SDCAPCD, BAAQMD

13

14 Attachment A Review of BACT Determinations published by ARB B

15 List of BACT determinations published in ARB s BACT Clearinghouse for lithographic offset printing-non-heatset Source Date Equipment Description/ Capacity VOC Limit Control Description SCAQMD 3/16/2000 Air dry; 12 printing units, 2,000 hp total press drive 309 lb/day VOC of fountain solution not to exceed 0.17 lb/gal and Ink VOC 300 g/l. SCAQMD 12/1/2000 Sheet fed, IR dried; 6-color, 40 sheet width, 21 IR lamps; 127 hp total press drive, 15,000 sheets/hr max 2730 lb/month Fountain solution < 0.2 lb/gal SCAQMD 8/19/1999 Sheet fed, single color; 40 sheet width 667 lb/month Fountain solution < 8% by volume SCAQMD (A) 2/2/2000 Offset lid printer (dry lithographic); 6 color printing units,15 inch sheet width w/a.3 kw UV 240 lb/month UV curable inks and wash solutions in compliance with SCAQMD Rule 1171 (A) Noted in the clearinghouse as Not yet a BACT Determination-Considered as AIP = Selected as the most stringent BACT determination achieved in practice. BACT Template Version

16 Attachment B Cost Effectiveness Analysis for Carbon Adsorption B

17 COST EFFECTIVENESS ANALYSIS FOR CARBON ADSORPTION This cost effectiveness analysis was performed using EPA's OAQPS Control Cost Manual EPA publication no. 452/B EQUIPMENT DESCRIPTION: Lithographic Offset Non-Heatset Printing Press VOC Parameters VOC of concern (using the physical properties of toluine) Various Cost of pure VOC ($/ton) 100 Molecular weight of VOC Emission rate (lbs/hr - inlet) 1.13 Inlet concentration (ppm) 10 k factor m factor 0.11 Partial pressure (psi) Gas Parameters Total gas flow rate (acfm - inlet) 8,000 Total gas pressure (psi - inlet) 14.7 Equipment Parameters Removal efficiency (%) 98.5% Adsorption time (hours) 16 Desorption time (hours) 8 Carbon Beds 1 Equipment life (years) 10 Operating Parameters Hours per day 16 Days per week 5 Weeks per year 52 Carbon Requirements Carbon working capacity (lb VOC/lb carbon) Amount of carbon needed (lbs) (k factor)*((partial pressure)^(m factor))/ (Emission Rate)*(hrs/day)/(Carbon Working Capacity) 173 ($1/lb carbon)*(lbs of carbon Carbon cost needed) $173 Carbon life (years) 5 Adsorber Vessel Dimension and Cost

18 Superficial bed velocity (ft/min) 75 Diameter of each vessel (ft) 0.21 Length of each vessel (ft) 518 Surface area (sq. ft) 335 Fm factor (see Control Cost Manual, p 4-24) 1.3 Cost per vessel $32, Adsorber Equipment Cost $57, Direct Costs: Purchased Equipment Cost Adsorber and auxiliary equipment To be conservative assume auxiliary costs = $0 $57, Instrumentation 1% of equipment cost $5, Sales taxes 8.5% of equipment cost $4, Freight 5% of equipment cost $2, Total Purchased Equipment Cost $70, Direct installation costs Foundations & supports 8% of total equipment cost $5, Handling & erection 14% of total equipment cost $9, Electrical 4% of total equipment cost $2, Piping 2% of total equipment cost $1, Insulation 1% of total equipment cost $ Painting 1% of total equipment cost $ Direct installation costs $21, Total Direct Cost Total equipment cost + Direct installation costs $92, Indirect Costs: Indirect Costs (installation) Engineering 10% of total equpment cost $7, Construction and field expenses 5% of total equipment cost $3, Contractor fees 10% of total equpment cost $7, Start-up 2% of total equipment cost $1, Performance test 1% of total equipment cost $ Contingencies 3% of total equipment cost $2, Total Indirect Costs $22, Total Capital Investment total direct cost + total indirect costs $114, Interest Rate 0.05 Equipment Life (years) 10

19 Capital Recovery Factor (CRF) Capital recovery cost (total capital investment)*(crf) $14, Capital Recovery Inflation adjustment (capital recovery cost)*[( )^6] $17, Direct Annual Costs Operator wage ($/hr) Maintenance wage ($/hr) operator hour (hrs/shift) 0.5 shifts per day (shift/day) 2 days of work per year (days/year) 260 Operator labor (labor wage)*(hours/shift)* Operator (shifts/day)*(days/year) $4, Supervisor 15% of operator labor $ Maintenance Maintenance labor (labor wage)*(hours/shift)*(shifts/day)*(da ys/year) $4, Materials 100% of maintenance labor $4, Utilities System Fan (kwh/yr) Refer to EPA cost manual 7340 Bed drying/cooling fan (kwh/yr) Refer to EPA cost manual 4 Cooling water pump (kwh/yr) Refer to EPA cost manual 28 Total Power Used (kwh/yr) 7372 Electricity Cost 0.13 $/kwh = SMUD Medium General Service Summer On-Peak Rate $ Steam Cost $ Cooling water $ Carbon Replacement Interest Rate 0.05 Carbon Life (yrs) 5 Capital Recovery Factor Replacement Labor CRF*$0.05/lb*carbon needed $2.00 Carbon Cost CRF*initial carbon cost* $43.40

20 Total Direct Annual Costs $15, Indirect Annual Costs Overhead 60% of maintenance labor and materials $2, Administrative Charges 2% of Total Capital Investment $2, Property Tax 1% of Total Capital Investment $1, Insurance 1% of Total Capital Investment $1, Total Indirect Annual Costs $7, Total Annual Costs Tons VOC reduced Cost of VOC Removal CRC and Inflation Total Capital Investment + Total Direct Annual Costs + Total Indirect Annual Costs $40, (Emission Rate)*(reduction efficiency)*(hrs/yr)/ (Total Annual Costs)/(Tons VOC Controlled) $17,505.18

21 Attachment C Cost Effectiveness Analysis for Thermal Oxidizers

22 COST EFFECTIVENESS ANALYSIS FOR THERMAL INCINERATION This cost effectiveness analysis was performed using EPA's OAQPS Control Cost Manual EPA publication no. 452/B EQUIPMENT DESCRIPTION: Lithographic Offset Non-Heatset Printing Press VOC Parameters VOC of concern (Using the physical properties of toluine) Various Molecular weight of VOC Heat of combustion (Btu/lb) 17,601 Heating value of VOC (Btu/scf) 4,074 Emission rate (lbs/hr - inlet) 7.6 Inlet concentration (ppm) 66 Gas Parameters Total gas flow rate (scfm - inlet) 8000 Total gas pressure (psi - inlet) 14.7 Inlet gas temperature (deg F) 71 Equipment Parameters Level of energy recovery (0%, 35%, 50% or 70%) 70% Control efficiency (%) 98.5% Equipment life (years) 10 Operating Parameters Hours per day 16 Days per week 5 Weeks per year 52 Shifts per day 2 Incinerator Parameters Volumetric heat of combustion of effluent (Btu/scf) 0.27 Heat of combustion per pound of effluent (Btu/lb) 3.67 Temperature Required for incineration (deg F) 1, Gas temperature at exit of pre-heater (deg F) 1, Effluent gas temperature (deg F) Electricity Usage Price of electricity ($/kwh) $0.13 System fan (kwh/yr) 123, Total Power Used (kwh/yr) 123, Gas Usage Price of gas ($/1000 cu.ft.) $3.30

23 Auxiliary fuel required (scfm) CAPITAL COST Direct Costs: Incinerator $201,840 Auxiliary equipment (if not included above) $0 Equipment Cost (A) $201,840 Instrumentation (0.1A if not included above) $20,184 Sales taxes (0.085A) $17,156 Freight (0.05A) $10,092 Total Equipment Cost (B) $249,273 Direct Installation Costs: Foundation & Supports (0.08B) $19,942 Handling & erection (0.14B) $34,898 Electrical (0.04B) $9,971 Piping (0.02B) $4,985 Insulation for duct work (0.01B) $2,493 Painting (0.01B) $2,493 Direct Installation Cost $74,782 Site preparation $0 Facilities & buildings $0 Indirect Costs (installation) Total Direct Costs $324,054 Engineering (0.10B) $24,927 Construction & field expenses (0.05B) $12,464 Contractor fees (0.10B) $24,927 Start-up (0.02B) $4,985 Performance test (0.01B) $2,493 Contingencies (0.03B) $7,478 Total Indirect Costs $77,275 TOTAL CAPITAL INVESTMENT $401,329 ANNUAL COST Direct Annual Costs Operating Cost Operator $15.64/hr &.5 hr per shift ) $4, Supervisor (15% of operator) $609.96

24 Operating materials $0.00 Maintenance Utilities Labor &.5 hr per shift) $4, Material (same as labor) $4, Price of electricity ($/kwh) $0.13 Price of gas ($/1000 cu.ft.) $3.30 Electricity ($/yr) $16, Natural Gas ($/yr) $143, Total Direct Costs $172, Indirect Annual Costs Overhead $8, Administrative charges $8, Property taxes $4, Insurance $4, Interest rate (%) 5% Equipment life (years) 10 CRF Capital recovery $65, Capital Recovery Inflation Adjustment $76, Total Indirect Costs $101, TOTAL ANNUAL COST $274, Annual Cost ($/yr) $274, Annual Emissions Reductions (tons/yr) (annual emissions based on BACT determination limit for add-on controls) COST PER TON OF VOCs REDUCED ($/ton) $17,500.00